Transcription

1 1. INTRODUCTION 1.1 On 26 April 2001, ICASA, in terms of section 31 (5) of the IBA Act, 1993, invited interested parties to give written input on the draft broadcast frequency plan ( draft plan ) and policy issues laid out in section 2 of the document. The National Association of Broadcasters ( the NAB ) welcomes the opportunity to make these written representations. 1.2 The NAB is the leading representative of South Africa s broadcasting industry representing: All television broadcasters; SABC radio stations, 13 commercial radio broadcasters and 39 community radio broadcasters; Both the common carrier and the selective and preferential carrier licensed signal distributors. 2. GENERAL COMMENTS 2.1 The NAB notes that the publication of the draft frequency plan comes at a time when the regulator is facing severe constraints in its broadcast frequency planning capacity. It appears that these constraints have had an impact on the regulator s ability to deal effectively and comprehensively with many issues laid out in the plan, especially in relation to data accuracy and international coordination. These matters are dealt with in more detail in sections 3, 4 and 5 of this document.

2 2.2 The NAB further notes that the frequency plan should contribute to the stability of the broadcast industry by laying out current usage of frequencies and indicating future requirements. 2.3 The NAB believes that, unfortunately, the number of omissions and inaccuracies in the draft plan mean that instead of stability, instability and uncertainty may be created for the industry. 2.4 The NAB is of the view that rectifying these issues should be a priority for both the regulator and the broadcast industry. 2.5 The NAB therefore recommends that ICASA consider establishing a liaison committee with industry representatives in order to rectify problems in the draft plan. 2.6 In this regard, the NAB refers ICASA to Chapter 4 of ITU-R Report SM Economic Aspects of Spectrum Management. 2.7 This report recognises that administrations often have limited financial and human resources that can be applied to spectrum management. In some cases, these limitations can delay or restrict the implementation of communications systems vital to the national economy. Therefore, alternatives to traditional, spectrum management systems need to be considered, particularly when they are shown to be less expensive or less resource consuming. 2.8 According to the report, a number of administrations have made use of spectrum management resources outside the national spectrum manager including: communication groups with a direct interest in spectrum such as 2

3 advisory committees, trade associations, professional organisations, and quasi-governmental associations; frequency co-ordinators (and co-ordination groups) and designated spectrum managers; and spectrum management consultants, and support contractors. 2.9 These alternatives can be used to support the national spectrum manager in performing spectrum management functions. The objectives of using groups outside the national spectrum manager to assist in the spectrum management process are: to save financial or human resources; to increase the efficiency of spectrum use; to improve the efficiency of the frequency assignment and coordination processes; or to rationally supplement the expertise of the national spectrum manager The NAB recommends that ICASA consider the use of such a group in order to supplement its expertise in frequency management. The NAB would be very happy to make some of its members available to serve on such a committee. 3. OMISSIONS FROM THE PLAN 3.1 A broadcasting plan also serves as an information document, not only for existing broadcasters but also for prospective investors in the broadcasting industry. For this reason, the NAB is of the view that the plan should be as comprehensive as possible. 3

4 3.2 ICASA notes that the draft plan does not make provision for any terrestrial digital broadcasting. Although ICASA has facilitated test transmissions of DAB and DTT, the NAB is concerned that this matter has not yet been given attention in the frequency plan. We wish to encourage the Authority to move forward on the introduction of digital broadcasting in South Africa. 3.3 In order to balance universal service obligations and a diversity of services, the planning process needs to take into account all available technologies. The NAB believes that consideration must therefore be given to the role digital radio and television may be able to play in achieving a universal public broadcasting service and a diversity of other services. In many countries, firm timetables have already been established for the implementation of these technologies. 3.4 As far as terrestrial digital broadcasting is concerned, the NAB recommends that, as a starting point, the following issues need to be addressed: planning criteria, technical criteria, frequency bands, minimum field strengths, protection ratios and locations. 4 PRINCIPLES OF THE PLAN 4.1 CATEGORISATION OF THE PLAN The NAB is in broad agreement with the categorisation of the plan. However, we believe that there is a need for more flexibility so that categorisations can be changed. This will ensure that frequencies do not remain unused in a particular category whilst broadcasters in another category cannot be granted licences due to a lack of frequencies. 4

5 4.1.2 In this regard, the NAB recommends that spare frequencies in Johannesburg and other metropolitan areas be re-evaluated to determine whether they should still be reserved for certain categories of services or whether the categorisations should be changed We also recommend that the Authority specify a procedure which states under what conditions the categorisation of an assignment may be changed and the process for the change. 4.2 UNIVERSAL SERVICE OBLIGATIONS The NAB submits that the minimum field strengths used to determine coverage need to be re-evaluated in order to determine whether they are still appropriate. 4.3 PROTECTION OF EXISTING BROADCASTING SERVICES The NAB notes that ICASA has been very active in increasing the frequency assignments in the ITU Frequency Plans for VHF-FM Sound Broadcasting and VHF/UHF TV Broadcasting in South Africa. The assignments for the Ge84 FM Plan increased from 1011 to 1369 (+378) and for the Ge89 TV Plan the increase is 739 frequencies to 1948 frequencies (+ 1209). This is a remarkable increase in the assignment of the Sound and Television Broadcasting frequencies in the VHF and UHF bands However, this increase raises questions as to what extent existing broadcasting services are protected and what the effect is of these assignments on broadcasting assignments in neighbouring countries that are in conformity with the Plan. 5

6 4.3.3 The NAB is concerned that the draft plan fails to give any assurance that the service areas of existing broadcasting assignments remain protected against harmful interference resulting from the inclusion of additional frequency assignments in the draft plan The NAB submits that broadcasters and signal distributors must be given the necessary assurance in the plan that the service area of any assignment is not being adversely affected by the inclusion of additional assignments The NAB further submits that where frequency changes are necessitated, possible prejudice against existing operators must be guarded against. ICASA should make provision for a consultation process on changes which could be detrimental to existing broadcasters. Finally, the NAB submits that in cases where changes are made, the operator necessitating the change should be responsible for meeting the costs of this change. 4.4 EFFICIENT USE OF THE NATIONAL BROADCAST FREQUENCY SPECTRUM The Authority notes in section 2.7 that this plan differs drastically in the number of frequency assignments, from that provided in the ITU Regional African Frequency Assignment Plans for television and for VHF/FM sound The NAB submits that the Authority must ensure that it complies with all ITU plans. In this way, the Authority will contribute to creating the necessary stability in the industry (see also paragraph 4.7). 6

7 4.4.3 It would appear that Terrestrial Broadcasting Frequency Assignments in South Africa are not being notified in accordance with the ITU Convention and Radio Regulations The NAB notes that as all new assignments made by ICASA have no international protection, and are in conflict the ITU Radio Regulations, this matter should be addressed with utmost urgency. 4.5 FAIR COMPETITION The NAB is of the view that fair competition should also be interpreted to mean equitable access to frequencies by public, commercial and community broadcasters. 4.6 PROMOTION OF STABILITY IN THE BROADCASTING INDUSTRY The NAB submits that the promotion of stability in the broadcasting industry is one of the key functions of a frequency plan. The NAB further submits that, due to the failure of the Authority to notify the ITU of allocations, this is not currently being achieved The NAB submits that this issue must be rectified as a matter of urgency. 4.7 TERRESTRIAL DAB The NAB notes that as South Africa has not formally adopted a terrestrial audio digital standard, reference should be made to Digital Sound Broadcasting rather than DAB. 7

8 4.7.2 The NAB notes that ICASA believes that the use of existing terrestrial AM bands is not a practical proposition. The NAB believes that there is currently considerable work being done on the introduction of digital broadcasting in the frequencies below 30MHZ within ITU-R study groups. The NAB therefore proposes that ICASA give consideration to this matter. 4.8 DATA ACCURACY The NAB agrees with ICASA that the accuracy of the data in the Broadcast Frequency Plan is of a crucial nature. The NAB is therefore disturbed that there appear to be many inaccuracies in the draft plan By way of example, the following allocations are absent from the plan: - Pretoria Ukhozi FM - Fish Hoek P4 - Paarl P4 - Somerset West P4 - Stellenbosch P There are many more inaccuracies in addition to the ones mentioned above. We believe Sentech will provide a full list of these in their submission to the Authority It is worrying to the NAB that the mistakes in the draft plan of 1999 which were pointed out, appear to have been repeated. Also, outdated programme service names have not been altered. 8

9 4.8.5 It is also of concern that most of the technical licence amendments which have occurred in the last few years do not appear to have been captured in the plan The NAB submits that the accuracy of the plan is of critical importance and that the Authority should address this as a matter of urgency. 5 THE FREQUENCY PLANNING AND ASSIGNMENT PROCESS 5.1 COMPLIANCE WITH INTERNATIONALLY ACCEPTED METHODS The NAB is not aware whether the frequency plan has been reviewed against ITU criteria since Unless this has been done, there is no way knowing whether the draft plan is consistent with international practice The NAB recommends that a review of the draft plan against ITU criteria be conducted as a matter of urgency IMT ICASA states that the UHF TV band was one of the core bands identified for the terrestrial component of IMT The NAB submits that this statement is incorrect At the 1992 World Administrative Radio Conference held in Malaga-Torremolinos the core bands for IMT-2000 were identified. These core bands are defined in S5.388 of the ITU Radio Regulations and are MHz and MHz. 9

10 5.2.3 ITU Radio Regulation S5.317A adopted at WRC-2000 reads in full: " Administrations wishing to implement IMT 2000 may use those parts of the band MHz which are allocated to the mobile service on a primary basis (our emphasis) and are used or planned to be used for mobile systems (see Resolution 224 (WRC-2000)). This identification does not preclude the use of these bands by any application of the services to which they are allocated and does not establish priority in the Radio Regulations In ITU Region 1 the band MHz is allocated to the broadcasting and fixed services on a primary basis. The UHF television broadcasting band in South Africa extends to 854 MHz South Africa cannot introduce IMT-2000 in the UHF television broadcasting band at present as in Region 1 this band is currently not allocated to the mobile service. It should further be noted that S5.317A is only applicable in Region 1 to the frequency bands MHz, MHz and MHz The band MHz is allocated to the broadcasting, fixed and mobile services, all on a primary basis At WRC-97 South Africa relinquished its right to the broadcasting allocation in the band MHz. In South Africa, therefore, the introduction of IMT-2000 on frequencies below 1 GHz can only be considered in the bands between MHz and these are not broadcasting bands. 10

11 6 CONCLUSION 6.1 The NAB wishes to thank the Authority for the opportunity to make these written representations. Should there be the opportunity to make oral representations, the NAB would like to address the Authority. 6.2 The NAB also repeats its request that the Authority consider establishing a liaison committee with industry representatives in order to address some of the concerns laid out in this submission. 11

NATIONAL ASSOCIATION OF BROADCASTERS SUBMISSION TO THE PARLIAMENTARY PORTFOLIO COMMITTEE ON SCIENCE AND TECHNOLOGY ON THE ASTRONOMY GEOGRAPHIC ADVANTAGE BILL [B17-2007] 20 JULY 2007 1. INTRODUCTION 1.1

6.3 DRIVERS OF CONSUMER ADOPTION The main drivers for the take-up of DTT by consumers in South Africa are likely to be: Affordability of STBs and potential subsidies for STBs is the single most important

NAB WRITTEN SUBMISSION TO THE INDEPENDENT COMMUNICATIONS AUTHORITY OF SOUTH AFRICA ON THE DRAFT UPDATE OF THE NATIONAL RADIO FREQUENCY PLAN 3 FEBRUARY 2017 Table of Contents 1. Introduction... 3 2. Background...

11.5.2010 Official Journal of the European Union L 117/95 COMMISSION DECISION of 6 May 2010 on harmonised technical conditions of use in the 790-862 MHz frequency band for terrestrial systems capable of

FAQ s ABOUT DTT 1. What is DTT? - DTT stands for Digital Terrestrial Television or Digital Terrestrial Transmission. It refers to the broadcasting of terrestrial television in a digital format. Currently,

1 Wireless Telegraphy Act 2006 Licence for the transmission of digital terrestrial television multiplex service Date of Issue 6 July 2007 Licensee Company number (if a company) Registered address of Licensee

e.tv SUBMISSION ON DRAFT SPECTRUM ASSIGNMENT PLAN FOR THE COMBINED LICENSING OF THE 800MHZ AND 2.6GHZ BANDS 29 February 2012 1 1 INTRODUCTION 1.1 On 15 December 2011 in Notice 911, ICASA published Government

Introduction of WSD in the UHF Band in Europe from a Broadcaster s Perspective 29.11.2011 International Spectrum Management Dr. Roland Beutler Broadcasting and WSD in UHF Terrestrial Broadcasting in Europe

Government Gazette Staatskoerant REPUBLIC OF SOUTH AFRICA REPUBLIEK VAN SUID-AFRIKA Vol. 572 Pretoria, 18 February Februarie 2013 No. 36170 N.B. The Government Printing Works will not be held responsible

POST ASO WITH A SPECIAL REGARD TO THE SITUATION IN GERMANY Elmar Zilles Head Broadcasting, Federal Network Agency, Germany Regional Workshop on Spectrum Management and Transition to Digital Terrestrial

Conversion of Analogue Television Networks to Digital Television Networks Sara Elvidge-Tappenden Spectrum Planning Group, BBC R&D 1 Introduction There are many possible planning approaches for the design

VHF/UHF frequency coordination Central America & Caribbean To secure the operation of broadcasting stations and benefit from the Digital Dividend Following the: With the participation of: Central American

THE NATIONAL ASSOCIATION OF BROADCASTER S WRITTEN SUBMISSION ON THE INDEPENDENT COMMUNICATIONS AUTHORITY OF SOUTH AFRICA S DISCUSSION DOCUMENT ON THE REGULATION OF IPTV AND VOD 26 MARCH 2010 1. Introduction

5.3.3 Existing Digital Broadcasting Satellite Model in South Africa Currently, the only digital broadcasting services (excluding, alternative platforms such as 3G used for digital broadcasting) available

Broadcasting Digital Migration Made Easy Preamble Television broadcasting in southern Africa commenced around 1974. The analogue broadcasting standard employed was PAL I. As is the case for the rest of

GODIGITAL SOUTH AFRICA BROADCASTING DIGITAL MIGRATION (BDM) A Z the doc The Department of Communications (DoC) developed the Go DIGITAL South Africa booklet to educate, inform and create awareness about

CONSULATION PAPER ON LICENSING FRAMEWORK FOR DIGITAL TERRESTRIAL TELEVISION Itumeleng Batsalelwang FOREWORD Digital broadcasting has revolutionized broadcasting significantly. It has brought about many

Terrestrial Digital Audio Broadcasting in Europe T. (EBU) In just eight short years, Digital Audio Broadcasting (DAB) has progressed from largely unproven theories through practical experimentation, to

NAB Page 1 1. INTRODUCTION 1.1. On 7 December 2000, the Independent Communications Authority of South Africa ( the Authority ) published its Discussion Paper on the Review of Local Content Quotas ( the

Response to the "Consultation on Repurposing the 600 MHz Band" Canada Gazette, Part I SLPB-005-14 December, 2014 Submitted By: February 26th, 2015 1 DISCLAIMER Although efforts have been made to ensure

SUBMISSION BY THE NATIONAL ASSOCIATION OF BROADCASTERS IN RESPONSE TO THE NOTICE IN RESPECT OF THE DRAFT LOCAL AND DIGITAL CONTENT STRATEGY 20 October 2009 1 INTRODUCTION 1.1 The National Association of

VHF/UHF frequency coordination Central America & Caribbean To secure the operation of broadcasting stations and benefit from the Digital Dividend Following the: With the participation of: Central American

Submission to Inquiry into subscription television broadcasting services in South Africa From Cape Town TV 1 1. Introduction 1.1 Cape Town TV submits this document in response to the invitation by ICASA

Best Practice Regulatory Frameworks for Mobile TV forum Best Practice Regulatory Frameworks for Mobile TV June 2008 Information contained in this report only reflects solely the author s view on the subject

The long term future of UHF spectrum A response by Vodafone to the Ofcom discussion paper Developing a framework for the long term future of UHF spectrum bands IV and V 1 Introduction 15 June 2011 (amended

The Importance of Satellite Access to C Band Spectrum In Africa September 2012 INTRODUCTION Satellite systems and networks require hundreds of millions of Euros of investment, and years of advance planning

05/04/2018 EBU s reply to Ofcom s consultation: 'Invitation to tender for frequency blocks for the national provision of mobile telecommunications services in Switzerland', March 2018 The European Broadcasting

Switching to digital television The transition from analogue to digital television is well under way in a number of countries around the world. digital television allows for better picture and sound quality,

Broadcasting Ordinance (Chapter 562) Notice is hereby given that the Communications Authority ( CA ) has received an application from Phoenix Hong Kong Television Limited ( Phoenix HK ), a company duly

Policy on the syndication of BBC on-demand content Syndication of BBC on-demand content Purpose 1. This policy is intended to provide third parties, the BBC Executive (hereafter, the Executive) and licence

Ofcom's proposed guidance on regional production and regional programming Consultation document The Communications Act makes changes to the existing arrangements for a number of programming quotas that

All-digital planning and digital switch-over Chris Nokes, Nigel Laflin, Dave Darlington 10th September 2000 1 This presentation gives the results of some of the work that is being done by BBC R&D to investigate

TANZANIA COMMUNICATION REGULATORY AUTHORITY (TCRA) SECOND PUBLIC CONSULTATION DOCUMENT ON MIGRATION FROM ANALOGUE TO DIGITAL BROADCASTING IN TANZANIA THE CASE FOR THE ESTABLISHMENT OF THE MULTIPLEX OPERATOR

Australian Broadcasting Corporation submission to Australian Communications and Media Authority Digital Television codes and standards February 2008 ABC Submission in response to the ACMA discussion paper

User Requirements for Terrestrial Digital Broadcasting Services DVB DOCUMENT A004 December 1994 Reproduction of the document in whole or in part without prior permission of the DVB Project Office is forbidden.

European Broadcasting Union Union Européenne de Radio-Télévision 3 September 2009 EBU Response to the EC Consultation document 'Transforming the digital dividend opportunity into social benefits and economic

Digital dividend: challenges and opportunities in the new digital era Awarding the UK s digital dividend Matthew Conway, Director of Operations, Spectrum Policy Group February 24, 2009 1 What is the UK

UPDATE ON THE 2 GHZ BAS RELOCATION PROJECT March 30, 2009 On February 12, 2009, Sprint Nextel, the Association for Maximum Service Television, NAB, and the Society of Broadcast Engineers (referred to as

Broadcasting Order CRTC 2012-409 PDF version Route reference: 2011-805 Additional references: 2011-601, 2011-601-1 and 2011-805-1 Ottawa, 26 July 2012 Amendments to the Exemption order for new media broadcasting